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Location strategy · Customs · Operating substance

Hainan Free Trade Port vs Free Trade Zone

A Free Trade Port and a pilot Free Trade Zone are different things. Since island-wide customs operations began on 18 December 2025, Hainan is a special customs supervision area covering an entire province, while a pilot FTZ remains a defined area testing specific reforms.

Hainan FTP

Whole-island framework

All 35,400 km² of Hainan, operating under its own national law since 2021 and under island-wide customs supervision since December 2025.

Pilot FTZ

Defined test areas

Zones of tens of square kilometres inside a host city, created by State Council plans to trial investment and trade reforms.

Decision rule

Follow the operation

Locate where the business can actually keep customers, people, premises and compliant flows. Incentives follow qualifying activity, not the other way round.

01 / Compare the frameworks

The difference is legal basis, scale and customs treatment.

China's pilot free trade zone programme started in Shanghai in 2013 and has since been extended in successive rounds to more than twenty zones nationwide. Hainan is not one of them in the ordinary sense. It has its own statute, the Hainan Free Trade Port Law, passed by the Standing Committee of the National People's Congress on 10 June 2021, and it is the only place in China where a whole province sits inside a special customs supervision area.

QuestionHainan Free Trade PortPilot Free Trade Zone
Legal basisThe Hainan Free Trade Port Law (2021), plus a body of over 200 supporting policy documents.State Council plans and local regulations for each zone; no dedicated national law.
Geographic scopeThe whole of Hainan Island, about 35,400 km².A defined area, typically around 120 km², split into sub-zones within a host city or province.
Customs statusThe entire island is a special customs supervision area operating on "first line open, second line controlled, free movement within the island".Bonded zones inside the zone have special treatment, but the zone sits within the ordinary national customs territory.
Tariff modelSince closure, imports are governed by a negative list: goods outside the taxable catalogue enter free of import duty, import VAT and consumption tax.Standard national tariffs apply, with bonded treatment available in designated areas.
Headline tax rate15% corporate income tax for qualifying encouraged-industry companies with substantive operations; 15% cap on individual income tax for eligible high-end and urgently needed talent.The standard 25% corporate income tax rate applies unless a separate national incentive is available.
Foreign investmentA shorter Hainan-specific negative list applies in addition to the national one, with further openings under the Hainan FDI Regulations effective 30 July 2025.The FTZ negative list applies, which is already shorter than the nationwide list.
Company lawCompanies are still registered under national company and foreign-investment rules.The same national legal baseline applies.
Best fitBusinesses with a real Hainan operating, trade, processing or industry reason.Businesses matching a particular zone's functions, ecosystem and supply chain.
"Closure" does not mean the island is closed.

封关 refers to placing the whole island inside a customs supervision perimeter, not to restricting access. Travel between Hainan and the mainland continues normally, and people are not subject to customs clearance in the way goods are. What changed is how goods are treated when they cross into and out of the island.

02 / Island-wide customs operations

Map your goods across the first and second line.

This is the part that decides whether Hainan saves a goods business money or simply adds a step. Eight existing open ports, including Haikou Meilan and Sanya Phoenix airports and the ports of Haikou, Yangpu, Basuo, Sanya and Qinglan, serve as "first line" crossings with overseas. Ten new "second line" ports handle movement between Hainan and the mainland.

Outside mainland ChinaInternational markets
First line
into Hainan
Hainan FTPImport · Process · TradeGoods outside the taxable catalogue enter free of duty, import VAT and consumption tax
Second line
to mainland
Rest of mainland ChinaDomestic market

First line

From a positive to a negative list

Before closure, three zero-tariff catalogues covered roughly 1,900 tariff lines. Closure replaced that positive-list approach with a taxable-goods catalogue: anything not on it is duty free. Coverage rose to more than 6,600 tariff lines, roughly 74% of all categories, including most machinery, electrical equipment and industrial raw materials.

Second line

The 30% processing rule

Goods made by an encouraged-industry enterprise in Hainan using imported inputs may enter the mainland free of import duty if processing in Hainan adds 30% or more of value. Import VAT and consumption tax are still charged. The rule has applied since July 2021 and now covers the whole island.

Within the island

Free circulation between beneficiaries

Zero-tariff goods and products made from them circulate between eligible entities on the island without import taxes being clawed back. This is what makes Hainan attractive for processing and re-export rather than simply as an address.

The framework is highly relevant to goods businesses. A pure services company should not choose Hainan because it has heard the phrase "zero tariff", since most of the customs benefit will never apply to it. What island-wide customs operations mean for your business →

03 / The dual 15%

Two separate rates, two separate eligibility tests.

Hainan's headline tax incentives are often quoted as though registration were enough. It is not. Each rate has its own conditions, and both are time limited under the policies currently in force.

Corporate income tax

15% instead of 25%

Available to enterprises registered in Hainan and substantively operating there, whose main business falls within the Catalogue of Encouraged Industries for Hainan Free Trade Port. The policy was introduced by Circular Caishui [2020] No. 31 and extended through to 31 December 2027 by Caishui [2025] No. 3.

Read the 15% CIT guide →

Individual income tax

Capped at 15%

For high-end and urgently needed talent working in Hainan, against a national progressive scale that reaches 45%. Eligibility depends on the individual meeting Hainan's talent criteria and on genuine residence and work in the FTP, not on the employer's registration alone.

The condition people underestimate

Substantive operations

An address and a licence do not qualify a company for the 15% rate. The assessment looks at whether the company's production and operations, personnel, accounts and assets are genuinely in Hainan. In practice this means deciding where management sits, where employees actually work, where books are kept and where revenue-generating activity occurs, and then being able to evidence it if asked. Plan this before registration rather than after the first filing.

Read the substance guide →

04 / Location scorecard

Score the operating facts before the incentives.

A location works when several of these line up at once. If Hainan scores well on only the tax row, the plan is fragile: the incentive depends on the substance you may not be able to maintain.

Customers

Where contracts are signed and delivery happens

People

Where management and staff will actually be based

Goods

First-line and second-line flows, and processing value-add

Licences

Where permits and suitable premises are viable

Ecosystem

Banks, parks, suppliers, logistics and talent pool

Substance

Evidence you can maintain year after year

Location FAQs

Separate headline policy from eligibility.

What investors ask most often when comparing Hainan with a mainland free trade zone.

What is the difference between a Free Trade Port and a Free Trade Zone?

A pilot free trade zone is a defined area, typically around 120 square kilometres inside a host city, used to test investment and trade reforms while remaining inside China's ordinary customs territory. The Hainan Free Trade Port covers an entire province of about 35,400 square kilometres, has its own national statute passed in 2021, and since 18 December 2025 the whole island operates as a special customs supervision area.

What does Hainan's island-wide customs closure actually mean?

Closure, or 封关, means the whole island was placed inside a customs supervision perimeter on 18 December 2025, operating on the principle of "first line open, second line controlled, free movement within the island". Goods from overseas enter Hainan with liberalised treatment, while movement from Hainan into the rest of mainland China is supervised as an import.

Is Hainan closed off to visitors now?

No. Closure applies to customs treatment of goods, not to people. Travel between Hainan and the rest of China continues as normal, and the change does not restrict access to the island.

Does every import enter Hainan tariff-free?

No, but coverage is now broad. Closure replaced the former positive lists of roughly 1,900 zero-tariff tariff lines with a negative-list approach: goods outside the taxable-goods catalogue are exempt from import duty, import VAT and consumption tax. That covers more than 6,600 tariff lines, around 74% of categories. Treatment still depends on the goods, the importer's eligibility and the customs procedure used.

How can goods made in Hainan enter the mainland duty free?

Under the processing value-added rule, goods produced by an encouraged-industry enterprise in Hainan using imported inputs may enter the rest of mainland China free of import duty where processing in Hainan adds at least 30% of value. Import VAT and consumption tax are still payable. The policy has operated since July 2021 and now applies across the island.

Does every Hainan company receive the 15% corporate income tax rate?

No. The company must be registered in Hainan, carry out substantive operations there, and have its main business within the Catalogue of Encouraged Industries for the Hainan Free Trade Port. The incentive was introduced by Caishui [2020] No. 31 and extended to 31 December 2027 by Caishui [2025] No. 3.

What counts as substantive operation in Hainan?

More than a registered address and a licence. The assessment considers whether the company's actual production and business operations, personnel, financial accounts and assets are based in Hainan. It is worth planning where management sits, where staff work and where books are kept before registration rather than after the first tax filing.

Is there a 15% individual income tax rate in Hainan too?

Yes, for qualifying high-end and urgently needed talent working in the Hainan Free Trade Port, the individual income tax burden is capped at 15%, against a national progressive scale reaching 45%. Eligibility rests on the individual meeting Hainan's talent criteria and genuinely living and working there, not on the employer's registration alone.

Should a services company choose Hainan for the zero-tariff policy?

Usually not. Most customs benefits attach to goods that are imported, processed or traded. A consulting or software business will rarely use them, so the decision should rest on customers, staff, licensing and whether the corporate income tax conditions can genuinely be met.

Can a Hainan company sell to customers elsewhere in China?

Yes. A Hainan company is registered under the same national company law as any other Chinese company and can contract and invoice across the country. What changes is the customs treatment when physical goods move from Hainan into the mainland across the second line.

How does the Hainan negative list differ from the national one?

Hainan applies its own shorter foreign-investment negative list alongside the national one, and the Regulations on Foreign Investment in the Hainan FTP, effective 30 July 2025, opened further sectors including certain mining, value-added telecoms, healthcare and education activities. Whether your specific activity is open still needs to be checked against both lists.

Location assessment

Test whether Hainan fits the operating model.

Tell us where the customers, staff, management and goods will be, and which policies matter to the plan. Our Haikou team works inside the FTP every day.

  • Hainan versus other China locations.
  • Customs, licence and premises dependencies.
  • Tax eligibility and substance plan.

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Reviewed by Yanhua Lao, Hainan Company Formation Lead Last reviewed

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